DASCA – The Designer Anabolic Steroid Control Act of 2014

The Designer Steroid Control Act of 2014 (H.R. 4771), the latest in a long line of legislative actions intended to bring an end to the sale of anabolic steroids, was passed by a voice vote in the House of Representatives recently. The bill still needs to pass the Senate before being signed into law by the President, but the writing’s very much on the wall for the designer steroid market.
HR4771
There’s a lot of misunderstanding and misinformation surrounding DASCA, with some people claiming that it would outlaw anything that builds muscle, including things like protein and creatine, and others suggesting it just adds 25 new compounds to the Controlled Substances Act, and yet others claiming that prohormones would be fine if sold as “research chemicals”, so lets take a look at the bill in a little more detail.

Click here to read the complete bill

The bill starts off by adding a list of steroids to the controlled substances act. Nothing new there, there have been a number of such amendments to the CSA over the years. The 25 compounds to be added (and our brief descriptions or common names) are:

5α-Androstan-3,6,17-trione
(A saturated/’5a-reduced’ form of 6-oxo)

6-bromo-androstan-3,17-dione
(A saturated form of the aromatase inhibitor 6-bromoandrostenedione)

6-bromo-androsta-1,4-diene-3,17-dione
(6-bromoandrostenedione with additional C1-2 unsaturation)

4-chloro-17α-methyl-androsta-1,4-diene-3,17β-diol
(‘Halodrol’, an Oral Turinabol precursor)

4-chloro-17α-methyl-androst-4-ene-3β,17β-diol
(‘P-Mag’ or ‘Promagnon 25’, a methyl clostebol precursor)

4-chloro-17α-methyl-17β-hydroxy-androst-4-en-3-one
(17a-methyl clostebol)

4-chloro-17α-methyl-17β-hydroxy-androst-4-ene-3,11-dione
(‘Oxyguno’)

4-chloro-17α-methyl-androsta-1,4-diene-3,17β-diol
(‘Halodrol’ again, for some reason)

2α,17α-dimethyl-17β-hydroxy-5α-androstan-3-one
(Methasterone, or ‘Superdrol’. Note that this already appears on the CSA)

2α,17α-dimethyl-17β-hydroxy-5β-androstan-3-one
(An incorrect nomenclature occasionally listed on Superdrol bottles, see here)

2α,3α-epithio-17α-methyl-5α-androstan-17β-ol
(‘Epistane’ or ‘Havoc’)

[3,2-c]-furazan-5α-androstan-17β-ol
(‘Furuza’, a non-methylated analogue of Furazabol)

3β-hydroxy-estra-4,9,11-trien-17-one
(Theoretically a precursor to trenbolone; never released and probably never synthesized)

17α-methyl-androst-2-ene-3,17β-diol
(An analogue of desoxymethyltestosterone/madol/phera; never released and probably never synthesized)

17α-methyl-androsta-1,4-diene-3,17β-diol
(M1,4ADD, a precursor to methandrostenolone/Dianabol)

Estra-4,9,11-triene-3,17-dione
(‘Trendione’, a trenbolone precursor)

18a-Homo-3-hydroxy-estra-2,5(10)-dien-17-one
(M-LMG without the methoxy group, a precursor to 18-methyl-19-nortestosterone/13-ethylnortestosterone)

6α-Methyl-androst-4-ene-3,17-dione
(An aromatase inhibitor found in ProLine’s ‘Methyl-1 Pro’)

17α-Methyl-androstan-3-hydroxyimine-17β-ol
(‘The One’/’D-Plex’)

17α-Methyl-5α-androstan-17β-ol
(Methylandrostanol; ‘Protobol’)

17β-Hydroxy-androstano[2,3-d]isoxazole
(Androisoxazole)

17β-Hydroxy-androstano[3,2-c]isoxazole
(An isomer of androisoxazole)

4-Hydroxy-androst-4-ene-3,17-dione
(The aromatase inhibitor Formestane)

[3,2-c]pyrazole-5α-androstan-17β-ol
(Prostanozol, non-17a-methylated analogue of Stanozolol/Winstrol. Note 1: in the bill they have listed both this compound and formestane in the same subclause (lxxii), as if they were one item. Note 2: This compound already appears on the CSA))

[3,2-c]pyrazole-androst-4-en-17β-ol
(A 4,5 unsaturated analogue of the preceding compound)

[3,2-c]pyrazole-5α-androstan-17β-ol
(Prostanozol again)

Piecemeal changes to the law like this have historically essentially only driven innovation in the market, as small chemical changes to the steroid molecules created distinct compounds that were not covered by the legislation. So here’s where the legislators have taken a further step: the next paragraph redefines what is and isn’t considered an anabolic steroid in the eyes of the law.

If and when the bill passes, not only those compounds listed specifically (and esters and ethers thereof), but any “drug or hormonal substance (other than estrogens, progestins, corticosteroids, and dehydroepiandrosterone)” that “is derived from, or has a chemical structure substantially similar to, 1 or more anabolic steroids” in the list above “shall be considered to be an anabolic steroid for purposes of this Act” if it is intended to promote muscle growth, or marketed in that way. In previous steroid control acts it was specified that the drug needed to be “chemically and pharmacologically related to testosterone” in order to qualify – which put the onus on the DEA to undertake expensive and time-consuming research to demonstrate that the products they were looking to schedule were actually anabolic. DASCA, on the other hand, is satisfied that a compound is an anabolic steroid if it’s steroidal in structure and marketed as anabolic.

One other cause for possible concern is another caveat; that a (steroidal) compound may also be considered an anabolic steroid if it was produced with the intention of causing “a pharmacological effect similar to that of testosterone”. Testosterone is a hormone with a wide variety of effects – on mood, various kinds of behaviour (like risk-taking, for example), sex drive, hair growth (and loss), brain development and function, sperm development, fat distribution, and many more.

There are exemptions available from these rules; if the compound in question is “an herb or other botanical” or “a concentrate, metabolite, or extract of, or a constituent isolated directly from, an herb or other botanical”, is a dietary ingredient under the FFDCA, and “is not anabolic or androgenic”. And whereas in the past it has been up to the DEA to prove that a compound was anabolic and/or androgenic, if/when DASCA passes the burden of proof will be on those attempting to claim exemption.

DASCA also grants additional powers to the Attorney General, enabling them to issue a temporary order, without judicial review, adding substances to the list of anabolic steroids. This would take place no sooner than 30 days after publication of a notice in the Federal Register.

It will also become unlawful to import, export, manufacture, distribute, dispense, or possess with intent to manufacture, distribute, or dispense falsely labelled anabolic steroids, with penalties of up to $500,000 per violation (per instance of import/export etc.) for manufacturers and distributors, and $1000 per violation (i.e. per bottle) for retailers.

To summarize, the bill states that (as well as adding a specific list of 25 compounds) anything that is steroidal (and not an estrogen, progestin, corticosteroid, or DHEA) that is created, manufactured, or marketed as building muscle (or having other pharmacological effects similar to testosterone), unless it is a herbal extract and has no anabolic or androgenic effects, will be considered to be an anabolic steroid under the Controlled Substances Act (and therefore a Schedule III controlled substance).

This bill appears to finally close the designer steroid loophole that has been exploited for nearly 20 years – but the legislature has yet to acknowledge the growing grey market in non-steroidal SARMS like Ostarine.

Please note that the above lay analysis does not constitute legal advice. If you have legal concerns you could contact CMG’s supplement counsel.

© Total Flex Blog 2014

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